Analysis of Foreign Boards of Trade

In FY 2013, a new registered FBOT category will obviate the need for the current FBOT no-action letter program, but the substantive requirements that will be imposed on registered FBOTs will likely be more robust than the requirements imposed under the no-action regime. By FY 2013, up to 28 FBOTs will be registered. Currently, 20 FBOTs operate in the United States based upon no-action letters dating back to 1999. The Commission expects at least that number of FBOTs will apply to register upon the implementation of the FBOT regulations, plus an additional eight FBOTs who have recently expressed an interest in becoming registered.